Supplemental California Privacy Notice

Supplemental California Privacy Notice

This Privacy Notice for California Residents supplements our main privacy policy and applies to those who live in California and whose personal information Ubimo processes as a “business.” It does not apply to personal information we collect in the following circumstances:

From employees or job applicants in their capacity as employees or job applicants;

Personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services; and

Information that we process as a service provider on behalf of other businesses.

A. Categories of Personal Information that We Collect and Share

The California Consumer Privacy Act (“CCPA”) requires us to give California residents certain information about the categories of personal information we collect and how we use it, the categories of sources of the information, and the categories of third parties with whom we share the information during the past twelve months. While we have set out the categories below as required by the CCPA, you can review our main privacy policy for more detailed information that describes our collection, sharing, and use. Depending on how you interact with us, we may collect and share the categories summarized below.

Internet or Other Network or Device Activity (such as browsing history, search history, interaction with advertisements) excluding Contact Information and other data collected on our Website

Automatically collected from you or your device

Affiliates or subsidiaries

Service providers

Advertising and Measurement Partners

Demographic Information (such as state of residence, household income range, education level, occupation, and certain legally protected characteristics such as gender, age, ethnicity, and military service) excluding Contact Information and other data collected on our Website

Contact Information and other data collected from our Website which may constitute Identifiers, Commercial Information, Internet or Other Network or Device Activity, Demographic Information, or Location Information

Automatically collected from you or your device

Affiliates or subsidiaries

Service providers

None

Please note that we may also disclose all personal information to (a) comply with federal, state, or local laws; (b) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (c) cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (d) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (e) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

B. Categories of Business/Commercial Purposes for Our Use of Your Information

With the exception of Contact Information, all of the categories of personal information we collect about you (as detailed above) are used for the following purposes:

Delivering and measuring relevant ads, offers or promotions to you

For our operational purposes

Improving our existing Platform and developing new products and services

We also use your Device Data, PLI, and Combined Data to provide services for, and products to, our Advertising and Measurements Partners (as described in our Privacy Policy).

C. California Residents’ Privacy Rights

Subject to certain restrictions, California residents have the right under the CCPA to request that we:

Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.

Provide access to and/or a copy of certain information we hold about you.

Delete certain information we have about you.

Honor your opt-out of the “sale” of your information.

Note that in response to requests to access specific pieces of information we have collected that are only associated with a specific device identifier, we cannot provide such specific pieces of information because we are unable to adequately verify that the person who has submitted the request is the actual owner of the device associated with a given data set. For example, a person in possession of another person’s phone could potentially have access to that phone’s device ID, and submit an unauthorized access request by providing that ID. We seek to avoid a situation where such a person might obtain potentially sensitive data pertaining to the phone’s owner. Moreover, because we do not associate other personal information such as name, address or email address with this data, we do not have other, more conventional ways to adequately verify the identity of an actual device owner.

If you do submit an access request, we can let you know whether we generally have data associated with the device identifier you have submitted to us. If you prefer that we delete the information we have associated with your device, you can submit a deletion request as described below.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion, or sale opt-out rights. We will not discriminate against you for exercising your rights. Certain information may be exempt from such requests under applicable law. For example, for financial auditing purposes, and for compliance with applicable law.

The CCPA defines “sale” and “personal information” very broadly. Certain uses of your data described above may constitute a sale under the CCPA, as we currently understand it. If you would like to opt out of our use of your information for purposes that are considered a “sale” under California law, you may do so here. If you want us to delete tracking cookies that enable targeted advertising, which allow us to provide promotions and offers relevant to you, you may do so here. If you clear your cookies after you asked us to delete tracking cookies, we will not be able to know that you made this request so you will need to opt out again. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization. We do not sell the Contact Information you provide us through our website.

If you would like to exercise any of these CCPA rights, please visit our privacy portal or contact us at info@ubimo.com and include “CCPA REQUEST” in the email subject line. You will be required to verify your identify before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.